Settian Capital LP

Settian Capital commenced operations in May of 2018 and serves as an investment manager to a private fund (the “Private Fund”) and to separate accounts clients. In addition, Settian Capital may, as current or future circumstances arise: (1) manage special purpose vehicles formed for the purpose of making targeted investments; (2) provide consultative services to outside organizations relating to specific actions or investments; (3) offer non-discretionary investment management services to future clients; and/or (4) engage in other investment-related commercial activities as it deems appropriate in its sole discretion. The Private Fund commenced investment operations in January 2016 and was initially managed by Park Avenue Value Partners LP, a predecessor to Settian Capital. Investment management duties were transferred to Settian Capital LP in May of 2018. All entities referenced above are or were, as applicable, under the common control of Karl K. Segerberg (“Kristofer Segerberg”). The investment mandate of the Private Fund is described in the fund’s Private Placement Memorandum or other offering document, as applicable (“Offering Document”). Settian Capital provides discretionary investment advisory services to both the Private Fund and its separate account clients pursuant to applicable investment management agreements. A separate account client may impose restrictions upon investing in certain securities or types of securities at the inception of the relationship with Settian Capital or at any other time by writing to Kristofer Segerberg using the address provided on the front of this Brochure or by email at segerberg@settian.com. As of December 31, 2025, Settian Capital managed approximately $156 million in discretionary assets under management.

Settian Capital’s fee arrangements with the Private Fund provide for the payment of specified Settian Capital firm expenses as well management and performance fees, subject to high water marks. Certain clients and investors who are affiliated with Settian Capital are not charged management fees or performance-based fees. Settian Capital’s SMA fee arrangements generally provide for the payment of management fees based upon a percentage of a client’s assets under management and are stated in the client’s management agreement. Settian Capital generally receives between 0.5% and 1.5% per annum for its management of SMAs, provided that legacy seed clients, clients who are affiliated with Settian Capital and potentially other clients may receive more favorable terms. Settian Capital may also receive annual performancebased compensation as disclosed in the relevant SMA agreement and in accordance with all applicable laws. Management fees and performance-based fees are negotiable. Unless otherwise specified in the client agreement, client fees are generally deducted from client investment accounts. However, any client who wishes to be billed separately may contact Settian Capital at the number on the front of this Brochure. In the event of the termination of an investment management agreement between Settian Capital and a client, the client will receive a refund of pre-paid fees attributable to any period after termination, pursuant to the terms of such investment management agreement. Management fee refunds on intraperiod and partial withdrawals are based on the number of days left in the period and the amount withdrawn. These refunds are credited against the next management fee charged. Management fees on intra-period and partial withdrawals are not refunded where the cost of processing exceeds the amount due, as determined solely by Settian Capital.

Client assets, which are from time to time not invested in other securities, are generally invested in cash equivalents including demand deposits, time deposits, money market instruments or other short-term investment vehicles. In such cases, the client may pay the money market fund or other short-term investment vehicle an advisory fee on the assets invested in the fund or short-term investment vehicle in addition to the advisory fee paid to Settian Capital. The Private Fund and SMAs will generally bear expenses in connection with their trading and investment activities, which will generally include brokerage costs and other fees and expenses involved with their respective trading activities. Please see Item 12 below for a more detailed discussion of brokerage expenses and practices. The Private Fund also bears additional expenses associated with organizing, administering and continually offering the fund. Such expenses include legal, accounting, escrow, auditing, recordkeeping, administration, fund accounting, computer, clerical expenses, insurance, expenses incurred in preparing reports and tax information to investors and regulatory authorities, expenses of printing and dispatching materials and reports to investors, duplicating expenses, mailing costs, courier costs and filing fees, where applicable. These expenses are in addition to those also assessed for Settian Capital firm expenses. From time to time, Settian Capital may invest client accounts in an ETF or another pooled investment vehicle. Such investments are most likely to occur for cash management reasons, but Settian Capital may also choose to utilize these funds for other investment reasons when it believes that doing so is in the best interest of the clients. When Settian Capital invests an account in a pooled investment vehicle, the portion of each account that is invested in the fund will also be subject to additional fund-level expenses that would not exist for direct investments, including the fund-level expenses discussed in the paragraph above.

Sources of Information Settian Capital uses many sources of information in its analyses of securities. These sources include financial filings, business, economic, financial and other publications, trade journals, third-party data services, outside research and one-on-one conversations with company management teams, suppliers, customers, end users and sector specialists.

Investment Strategies Settian Capital’s investment strategy is to invest primarily in long and short positions in equity securities and equity-linked instruments. Settian Capital focuses on investments in the securities of U.S. issuers and other U.S. instruments but may also invest in non-U.S. securities and instruments on an opportunistic basis. Settian Capital may, but is not obligated to, seek to hedge downside risk. Settian Capital may employ leverage in its investment program. Settian Capital’s approach to portfolio management may be categorized by: 1. Fundamental Stock Selection: Settian Capital pursues a disciplined equity selection process emphasizing fundamental analysis of a company’s prospects for delivering improving returns on capital. In selecting equity securities for investment, Settian Capital may consider a number of different factors including, without limitation, one or more of the following: •

Review of fundamental characteristics indicating financial strength or weakness, such as profit growth analysis, business franchise characteristics, residual/transfer asset values, market position analysis, review of distribution systems, assessments of intellectual property assets and similar characteristics;

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Consideration of fundamental value strategy characteristics, such as cash flow or asset value analysis, review of exit alternatives, and non-traditional assessments of underappreciated, undervalued or hidden assets or future opportunities identified through research;

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Identification of catalysts for value realizations on a micro basis such as management changes, restructurings, new product cycles, or other micro developments and considerations; and

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Review of opportunities in light of business cycles (including, without limitation macro boom-bust reflexive sequences or cycles, the credit cycle, central bank behavior, currency markets and other critical global macro influences).

2. Concentration: Settian Capital intends to be invested on a more concentrated basis, which may cause investment performance to be significantly more volatile than would otherwise be the case.

The Investment typically expects the top 10 positions to be 40-60% of Settian Capital’s portfolio, though this may fluctuate over time. 3. Net exposure management: Settian Capital believes that portfolio net exposure may vary as may be appropriate in different market conditions. The relative mix between long and short positions may vary over time depending on the investment opportunities that are identified and Settian Capital’s view concerning the prospects for global economies and overall direction of global markets. Settian Capital believes that +60-100% net long may be appropriate in sustainable bull markets and (-20%) to (+20%) may be appropriate in sustainable bear markets; however, decisions of net exposure are left to the discretion of Settian Capital. There is no guarantee that Settian will choose to pursue short positions over any time horizon. In addition to the foregoing, in support of its fundamental research, Settian Capital may utilize technical analysis and any other methodology determined by Settian Capital as part of its research and investment selection process. In carrying out Settian Capital’s investment strategy, Settian Capital may invest in exchange traded funds and exchange traded notes, including commodity and fixed-income related exchange traded funds and exchange traded notes. Settian Capital may also purchase or sell exchange traded options for hedging purposes and/or as part of Settian Capital’s objective of obtaining exposure to the equity markets. In addition to, or in connection with, the foregoing, Settian Capital may use leverage in its investment program. The amount of leverage that may be employed by Settian Capital at a given time will be determined by Settian Capital. There are no material limitations on the securities or instruments in which Settian Capital may invest, the markets in which Settian Capital may trade, the market sectors in which the underlying issuers may operate, or the trading strategies that Settian Capital may utilize. However, Settian Capital expects to invest primarily in liquid equities and equity-linked instruments. Settian Capital will generally not invest more than 20% of Settian Capital’s assets in any long or short position of any one single issuer and will typically invest not more than 10% of a client’s account in any single long position at cost and not more than 4% of a client’s account in any single short position at cost. Securities representing multiple issuers, such as equity index ETFs, that may be used in hedging market risks and adjusting portfolio net exposure, are not considered subject to single position numerical limits. Settian Capital will generally not exceed 200% gross exposure (long exposure plus short exposure), 150% long exposures, and 100% short exposure.

Overview of Risk Factors Risks Applicable to all Settian Capital Clients: Arbitrage. Settian Capital may engage in various types of arbitrage. Arbitrage involves the purchase of an asset and the concurrent sale of that asset in a different market, or the sale of a related asset, in order to capture small price discrepancies between markets or related assets. Arbitrage strategies involving related assets carry the risk that the value of the related assets will not track or affect each other in the manner anticipated by Settian Capital. Arbitrage strategies generally assume the price of related assets will converge to some historic or quantitative relationship and that price discrepancies from this relationship will disappear. In the event the price discrepancies do not disappear or if the price discrepancies increase, a client’s investment account could lose money on an arbitrage trade. Depending upon the investment strategies employed and market conditions, a client’s investment account may be adversely affected by unforeseen events involving such matters as political crises, changes in currency exchange rates, interest rates, forced redemptions of securities or acquisition proposals.

Settian Capital may determine that the offer price for a security that is the subject of a tender offer is likely to be increased, either by the original bidder or by another party. In those circumstances, Settian Capital may purchase securities above the offer price, thereby exposing a client’s investment account to an even greater degree of risk. When Settian Capital determines that it is probable that a previously announced transaction involving a company will not be consummated, it may sell the securities of the target company short, at times significantly below the announced price for the securities in the transaction. If the transaction (or another transaction, such as a defensive merger or a friendly tender offer) is consummated at the announced price or a higher price, Settian Capital may be forced to cover the short positions in the market at a higher price than the short sale price, resulting in a loss. The consummation of mergers, exchange offers and cash tender offers can be prevented or delayed by a variety of factors. Offers for tender or exchange offers customarily include a reservation of the right to cancel such offers in a variety of circumstances, including an insufficient response from shareholders of the target company. Even if the defensive activities of a target company or the actions of regulatory authorities fail to defeat an acquisition, they may result in significant delays, during which an investment account’s capital will be committed to the transaction and interest charges may be incurred on funds borrowed to finance its arbitrage activities in connection with the transaction. Exchange offers or cash tender offers are often made for less than all of the outstanding securities of an issuer, with the provision that, if a greater number is tendered, securities will be accepted on a pro rata basis. Thus, after the completion of a tender offer, and at a time when the market price of the securities has declined below the price at which they were acquired, Settian Capital may have returned to it, and be forced to sell at a loss, a portion of the securities it had previously tendered. Settian Capital may make certain speculative purchases of securities. Such purchases may include securities of companies that are involved in, or which Settian Capital believes will be involved , corporate restructurings, that they believe are undervalued because of an extraordinary event, or that are expected to undergo a change in value because of an expected occurrence. Settian Capital may also make concentrated investments in securities of companies that may be or may become targets for takeovers. If Settian Capital purchases securities in anticipation of an acquisition attempt or reorganization or with the intention of influencing the management and policies of the issuer of the securities, and an acquisition attempt or reorganization does not in fact occur or they are not able to so influence the issuer of the securities, Settian Capital may have to sell the securities at a material loss. In most forms of corporate reorganization, there exists the risk that the reorganization either will be unsuccessful (for example, as a result of the failure to obtain requisite approvals), will be delayed (for example, until various liabilities, actual or contingent, have been satisfied) or will result in a distribution of cash or a new security the value of which will be less than the purchase price to Settian Capital of the security in respect of which such distribution was made. The securities industry, and the arbitrage business in particular, is extremely competitive. Settian Capital competes with firms, including many of the larger investment banking firms, which have substantially greater financial resources than does Settian Capital and substantially greater research staffs and more securities traders than does Settian Capital. In any given transaction, arbitrage activity by other firms may narrow the spread between the price at which a security may be purchased for a client account and the price it expects to receive upon consummation of the transaction. Accordingly, a client’s investment account may not achieve substantial profits on such transactions. Below Investment Grade Fixed Income Securities. Settian Capital may invest or hold securities rated lower than Baa by Moody’s, BBB by S&P’s, or the equivalent rating of another nationally recognized statistical rating organization (“NRSRO”), which are considered below investment grade, or in

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As described in Item 4 above, Settian Capital serves as the Manager to a private fund and separate account clients.

The Private Fund generally require a minimum initial investment of $500,000 from investors, as described in the Private Fund’s Offering Document. This minimum investment level, however, may be waived or modified. In order to invest in the Private Fund, an investor must be an “accredited investor” as defined by Regulation D under the Securities Act of 1933 and a “qualified client” as defined by Section 205 of the Investment Advisers Act of 1940 and Rule 205-3 thereunder. While Settian Capital has not determined a specific minimum investment for a separately managed account, Settian Capital’s services are generally geared towards family offices, institutional investors and platforms, wealthy individuals and others sophisticated investors whose assets under management allow Settian Capital to fully implement its investment management strategy.

As noted in Item 5, Settian Capital, or in the case of the private fund, an affiliate of Settian Capital, may also receive annual performance-based compensation as disclosed in the relevant Offering Document or investment management agreement, as applicable, and in accordance with all applicable laws. The performance-based compensation is outlined in the respective investment management agreement or offering materials for the respective product. Clients that are subject to performance-based compensation may be managed differently due in part to their broader investment mandates, differing tax ramifications and greater risk constraints and tolerances. This may result in materially different performance from that experienced by investors who are not invested in these products. The variation of performance-based compensation structures among Settian Capital’s clients may create an incentive for Settian Capital to direct the best investment ideas to, or to allocate or sequence trades in favor of, clients that pay or allocate performance-based compensation. Settian Capital has procedures designed and implemented to provide reasonable assurance that all clients are treated fairly. Specifically, Settian Capital maintains procedures designed to address the allocation of investment opportunities among clients as well as the manner in which investments are valued. See Item 12. In addition, the Private Fund retains a third-party administrator which independently calculates, among other things, profit/loss allocations, management fees and performance-based fees.

As previously noted in Item 4 above, Settian Capital sponsors and manages a private commingled investment vehicle. Investors should refer to the Private Fund’s offering documents for eligibility requirements, risks, redemptions, fees and other important information. As previously noted, Settian Capital may, as current or future circumstances arise: (1) manage special purpose vehicles formed for the purpose of making targeted investments; (2) provide consultative services to outside organizations relating to specific actions or investments; (3) offer non-discretionary investment management services to future clients; and/or (4) engage in other investment-related commercial activities as it deems appropriate in its sole discretion. Settian Capital also has two financial industry affiliates: (1) Park Avenue Value Partners LLC, a professional services consulting company; and (2) JAEK Capital Management LP, a professional research and support services company. All of the above entities are under the common control of Kristofer Segerberg. While Settian Capital will take reasonable steps to manage conflicts of interest between its activities and those of the affiliated entities, there can be no assurance that those efforts will be successful. It is possible that one or more of the affiliated entities may have a competing interest in one or more investments that might otherwise be suitable for Settian Capital clients. Additionally, given the nature of some of the investments that Settian Capital may make on behalf of clients, it is possible that conflicts may arise between the interests of Settian Capital or its control persons and those of clients managed by Settian Capital. For example, other business opportunities may arise from such investments which may benefit Settian Capital and/or its control persons. Settian Capital has adopted procedures to manage these conflicts which include, where applicable, notification and consent processes. There can be no assurance, however, that any procedure adopted to address this type of conflict will fully or partially mitigate the influence that such conflicts may exert over the investment decision-making process. Settian Capital may also manage proprietary accounts on behalf of certain members of the organization. These proprietary accounts may invest in certain securities also purchased and sold for client accounts. The trading of proprietary accounts by Settian Capital could create incentives for Settian Capital to

allocate trades, choose the timing of trades and divert limited investment opportunities in favor of these accounts. Settian Capital has adopted policies and procedures designed to mitigate potential investment allocation and trading preferences. However, there can be no assurance that these policies and procedures will always prevent the proprietary accounts from receiving more favorable treatment than one or more other accounts managed by Settian Capital.

Settian Capital has adopted a Code of Ethics (“Code”) pursuant to rule 204A-1 under the Advisers Act that is built on the principle that Settian Capital owes a fiduciary duty to its advisory clients and investors. The Code includes an Insider Trading Policy to establish principles of conduct and to detect and avoid conflicts of interest that may arise between employees and clients as a result of personal investing activities. The Code is designed to ensure, among other things, that employees conduct their personal investing activities in accordance with applicable law and in a manner where clients’ interests are placed first and foremost. Settian Capital’s Code applies to all employees of Settian Capital and any account in which an employee has control or a beneficial interest as well as the accounts of family members of each employee’s immediate household, as further described in the Code. The Code also requires employees to report all accounts and securities holdings covered by the Code at the commencement of their employment and annually thereafter. In addition, on a quarterly basis, all employees are required to report all securities transactions executed during the quarter. The Code also requires, among other things, that all employees pre-clear transactions in initial public offerings and private placements. Certain securities are exempt from the requirements of the Code including open-end mutual funds which are neither managed nor affiliated with Settian Capital, money market funds, money market instruments, unit investment trusts that are invested in open-end mutual funds and U.S. Government securities. The Code imposes specific prohibitions on employee trades including (i) trades based on material nonpublic information, (ii) trades intended to manipulate the market, (iii) trades in securities on Settian Capital’s restricted list, (iv) trades in securities subject to an open order or during the blackout period, subject to certain de minimis exceptions relating to large cap securities; and (v) trades in initial public offerings. Settian Capital’s Insider Trading Policy includes specific requirements regarding the possession of material non-public information (“MNI”) in order to avoid situations that may violate applicable statutes or regulations or create an appearance of impropriety. Settian Capital’s Insider Trading Policy strictly forbids any employee from (i) conducting trades, either personally or on behalf of others, including clients of Settian Capital, while in possession of MNI and from (ii) communicating MNI to others. All employees of Settian Capital must acknowledge that they understand the Code and agree to comply with it both upon initial employment and through annual certifications. Conflicts of interest that can impact Settian Capital and a client’s investment accounts, such as those arising from the giving and receipt of gifts to and from business partners, and the making of political contributions, are also addressed. A copy of Settian Capital’s Code of Ethics will be provided to any client, investor or prospective client or investor upon request. Settian Capital’s affiliates and certain employees of Settian Capital are members of one or more of the entities serving as general partner of the Private Fund. Employees of Settian Capital may maintain (either

directly or indirectly) investments in the Private Fund, and the general partner or a member of the general partner of the Private Fund makes a capital commitment to the Private Fund. The general partner of the Private Fund receives performance-based compensation. Furthermore, Settian Capital’s officers, directors and employees may from time-to-time purchase, sell, or hold positions for their personal accounts in securities that may also be, or have been or will be, purchased or sold for the accounts of Settian Capital’s clients. As noted in Item 10 above, Settian Capital may manage proprietary accounts on behalf of certain members of the organization. These proprietary accounts may invest in certain securities also purchased and sold for client accounts and may also purchase securities that are not acquired for client accounts. It is important to note that these accounts are not subject to the trading restrictions noted above with respect to personal securities accounts. Please see Item 12 below for more information regarding trading allocations, including those applicable to the proprietary accounts. Please also refer to Item 10 above for information regarding potential conflicts of interest.

Brokerage and Soft Dollars Settian Capital offers discretionary investment management services to its clients. As such, Settian Capital generally maintains discretion regarding all decisions as to which securities should be purchased and sold, the amount and price of those securities and the selection of commissions paid to brokers. At the present time, Settian Capital aggregates its trading accounts with a single brokerage platform. Settian Capital believes that the use of a single platform is designed to achieve purchasing power and efficiencies that might not otherwise be achieved by using multiple broker-dealers, particularly in light of Settian Capital’s current assets under management and low anticipated trading volumes. In choosing a broker-dealer platform through which to effect trades, Settian Capital seeks to select the broker-dealer on the basis of its capabilities, expertise in executing transactions for client accounts and its overall execution abilities. Given the use of a single platform, however, Settian Capital is limited in its ability to negotiate best price and execution on a per trade basis. Additionally, Settian Capital may pay brokerage commissions in excess of those which other brokers might have charged for effecting the same transactions. Other factors considered by Settian Capital in choosing a broker-dealer platform include the brokerdealer’s research products and services and the success of prior research recommendations (collectively, “Research”), and its ability to execute difficult trades (possible market impact, size of the order and market liquidity), commitment of capital, access to new issues, nature and frequency of sales coverage, depth of services provided, including economic or political coverage, back office and processing capabilities, financial stability and responsibility, reputation, access to markets, confidentiality, commission rate, and responsiveness to Settian Capital. As noted above, in return for effecting securities transactions through its broker-dealer platform, Settian Capital may receive Research which assists Settian Capital in its investment decision-making processes. Research may include, among other things, proprietary research from broker-dealers, which may be written or oral; software and related support services for use in research and trading and/or computer databases; market, economic and financial data and statistical information; data on pricing and the availability of securities; publications; access to conferences; electronic market quotations; performance measurement services; analyses and/or due diligence concerning specific securities, companies or sectors, including due diligence on specific aspects of a company's operations or finances; analyses on issues

raised in proxy statements; and market, economic and financial studies and forecasts. Research may be in written, oral or online format and may be produced by broker-dealers or third parties such as attorneys, accountants or consultants. When Settian Capital uses client commissions to buy Research, it receives an economic benefit because it does not have to furnish or pay for the Research itself. Because clients pay somewhat higher commissions to generate soft dollars, Settian Capital faces a conflict of interest between its need to access the Research and a client’s investment accounts’ interest in paying the lowest possible commission rates available. It is also possible that some clients who generate little to no soft dollar commissions may benefit from the Research obtained from commissions generated from other client accounts. Although the Research obtained by Settian Capital may be used to service some or all of Settian Capital’s clients, a brokerage commission paid by a specific client may be used to pay for Research that is not used in managing that specific client’s account. Settian Capital does not consider client referrals in selecting broker-dealers.

Aggregation and Allocation Practices Settian Capital will generally execute transactions for clients on an aggregated basis where possible and when Settian Capital believes that to do so would be in the best overall economic interests of the clients. In accordance with its fiduciary duty, it is Settian Capital’s policy that all clients be treated fairly, subject to client-imposed and other constraints. A number of factors are taken into consideration when allocating investment opportunities among Settian Capital’s clients, including investment objectives and strategies, risk tolerances, tax status, size of client accounts, size of available positions, current market conditions, total portfolio invested positions and the nature of the security to be allocated. From time to time, Settian Capital may be allocated the opportunity to purchase securities in initial public offerings expected to be heavily over-subscribed. These allocations may be offered to Settian Capital in part as a result of its usage of one or more brokerage platforms or firms. Settian Capital may allocate securities purchased in these offerings to client accounts based on a number of factors including the client’s investment objectives and strategies. Settian Capital may aggregate orders in which Settian Capital, its affiliates and/or employees have a financial interest, including but not limited to proprietary trading accounts managed on behalf of employees of Settian Capital. In such circumstances, no client will be favored over any other client. All orders in the same instrument that were aggregated and executed with a particular broker-dealer during a day will generally receive an average share price, pay the same commission rates, and share any brokerage costs or other expenses of the order on a pro rata basis, based on order size. All aggregated orders will generally be allocated according to the designations made by the portfolio manager of such client accounts. Client orders partially filled will, as a general matter, be allocated pro rata in proportion to each client's original order. Where it is not meaningful to allocate a small number of securities among the accounts participating in the transaction on a pro-rata basis, Settian Capital may allocate such securities to less than all of the participating accounts in a manner determined in good faith to be a fair and equitable allocation over time. Notwithstanding the above, due to differing tax ramifications, as well as dissimilar risk constraints and tolerances, accounts with similar investment mandates may trade the same securities at differing points in time or may not participate in trades in which other accounts may participate. Additionally, for the reasons noted above, certain accounts, including proprietary accounts as well as the Private Fund in which Settian Capital, its affiliates and/or employees (“Settian Capital Funds”) have a financial interest, may trade separately from other accounts and participate in transactions which are deemed to be inappropriate for other accounts with similar investment mandates.

Settian Capital or the Private Fund have entered into, and in the future may enter into, contractual agreements with individuals and organizations (hereafter referred to as "Agents") that solicit clients for Settian Capital or investors for the Private Fund. While the specific terms of each arrangement may differ, generally an Agent's compensation is based upon the value of assets of the referred clients managed by Settian Capital or investors who invest in the Private Fund or a portion of the management and incentive fee paid by such clients or investors. As disclosed to the client or investor, the Agent's compensation may or may not increase the referred client’s or investor's fees beyond that which Settian Capital would otherwise charge the client or investor for its investment management services. Settian Capital will benefit from arrangements whereby clients are referred directly to it and investors are referred directly to the Private Fund, since Settian Capital’s management fees are generally based upon a percentage of such client's or such investor’s assets under management. Thus, the more assets Settian Capital has under management, the higher its fee income.

Settian Capital does not have any disciplinary information to report at this time.

Settian Capital’s Portfolio Manager is responsible on an ongoing basis for evaluating investments, reviewing portfolios of each account and making asset allocation decisions. For purposes of this Brochure, the term “ongoing” shall mean daily and/or as-needed, depending upon the nature of a given portfolio, the securities in question, and potentially other factors. The portfolio reviews are made in accordance with the client’s investment objectives and pursuant to the stated investment strategies of the respective client. Portfolios are reviewed for performance, diversification, and risk. Investors in the Private Fund receive, at a minimum, annual audited financial statements pertaining to the Fund. From time-to-time Settian may, but is not obligated to, issue other communications to investors in the Private Fund regarding the fund’s portfolio and/or performance. Settian does not routinely issue portfolio and/or performance reporting to clients with separately managed accounts. Under normal circumstances clients should be able to access such information through their account custodians. Settian encourages any client which requires specialized portfolio and/or performance reporting to retain the services of a third-party account administrator.

Settian Capital is generally deemed to have constructive custody of the assets of the unregistered pooled investment vehicle for which it serves as investment adviser and/or to which an Settian Capital affiliate serves as General Partner or Manager. However, it is not required to comply (or is deemed to have complied) with certain requirements of Rule 206(4)-2 under the Advisers Act (the “Custody Rule”) with respect to the Private Fund because it complies with the provisions of the so-called “Pooled Vehicle Annual Audit Exception,” which, among other things, requires that (i) the Private Fund be subject to audit at least annually by an independent public accountant that is registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board, and (ii) the Private Fund distributes its audited financial statements to all investors within 120 days of the end of its fiscal year.

Settian Capital offers discretionary investment management services to its clients. As such, Settian Capital generally has discretion regarding all decisions as to which securities should be purchased and sold, the amount and price of these purchases and sales and the selection of and commissions paid to brokers. Any limitations on Settian Capital’s discretionary authority must be incorporated into the

investment management agreement. Settian Capital’s authority may be limited by client-imposed investment objectives and strategies. Settian Capital assumes any discretionary authority through the signed investment management agreement. From time to time, Settian Capital may, but is not obligated to, execute specific client transaction requests submitted for tax management purposes. Nonetheless, Settian Capital reserves the right to refuse any or all such specific requests. Settian Capital also may, in its sole discretion, limit any such transactions by account size, transaction size, operational complexity, or any other criterion as determined solely by Settian Capital.

Settian Capital has adopted policies and procedures that require it to evaluate and vote proxy issues in the best interests of its clients. Settian Capital has determined that it is in the best interests of its clients to vote proxies in a manner that furthers the economic interest of its clients with the objective of maximizing the ultimate economic value of the investment. Settian Capital’s policy requires that the firm vote proxies on behalf of all of its discretionary clients in a prudent manner considering the prevailing circumstances. In many instances, in the absence of a compelling reason to do otherwise, Settian Capital will vote proxies in accordance with management recommendations. Settian Capital believes that, in most instances, supporting the management of companies in which it invests serves the best financial interests of its clients. Nonetheless, Settian Capital maintains the right to vote in contravention of a recommendation made by management when Settian Capital believes that doing so is in the best interest of Settian Capital’s clients. Settian Capital has adopted specific procedures that address proxy voting responsibilities, material conflicts of interest, if any, record keeping, due diligence activities with respect to certain voting activities undertaken by the proxy voting service and disclosure requirements. Furthermore, as part of Settian Capital’s policy, the firm may abstain from voting a proxy when it is determined that the cost of voting the proxy exceeds the expected benefit to the client or, in the sole discretion of Settian Capital, when it believes that it is acting in the best interest of its clients. There may be occasions where the voting of proxies may present an actual or perceived conflict of interest between Settian Capital and its clients. Settian Capital will not vote proxies contrary to the best interest of its clients due to business or personal relationships with an issuer’s management, participants in proxy contests, corporate directors or candidates for corporate directorships, or where Settian Capital or an employee may have a personal interest in the outcome of a particular matter before shareholders. When there exists an actual or potential conflict of interest, Settian Capital will engage a third party to vote the proxies on behalf of clients. Settian Capital generally does not accept client directed proxy voting requests, but may do so, in its sole discretion, on a case-by-case basis. Any client who wishes to discuss a particular proxy vote may contact Kristofer Segerberg at the number on the front of this Brochure or by email at segerberg@pavpcapital.com. Clients may also contact Settian Capital to obtain information on how proxies were voted for a client and to request a copy of Settian Capital’s proxy voting policies and procedures. Settian Capital may, but is not obligated to, participate in and file class action lawsuit claims on behalf of all of its clients. Settian Capital may determine not to file a claim on behalf of a client account for reasons including but not limited to the following: (i) in cases where a client account has closed prior to a class action lawsuit being filed, Settian Capital may not file a claim on such client’s behalf due to

administrative burdens outweighing anticipated benefits to the client; (ii) after conducting a cost-benefit analysis, Settian Capital may choose not to file a claim on a client’s behalf where the cost of filing would exceed any anticipated benefits to the client; and/or (iii) circumstances in which Settian Capital believes that participation in the class action suit could otherwise be harmful to existing clients’ interests. Additionally, Settian Capital cannot guarantee that it will be notified of any particular class action suit in a timely manner.

Settian Capital does not require or solicit prepayment of more than $1,200 in fees six months or more in advance and has not been subject to a bankruptcy petition within the past ten years. Additionally, Settian Capital does not have any financial condition that is likely to impair its ability to fulfill its contractual obligations.